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Legit Setup or Overcomplicated? Feedback on OCI’s Foundation + IBC Structure

#21
Protect Your Wealth said:
It works until you are investigated and authorities find out the director/shareholder is a nominee, then the company is treated as transparent and the nominee is bypassed attributing the ownership and control of the company to you.
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Not even.

Seychelles is really big on sharing information with foreign governments even when there is no count order.

Seychelles isn’t an option for such uses as OP describes anymore. Any self respecting intermediary knows this.

Seychelles still has its place in structures when it comes to superyachts and private jets. Anything else .. avoid them like the plague.

Also its extremely difficult to open any bankaccount with a Seychelles entity.
 
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#22
anceps said:
Thanks again to everyone for the insights so far, I’ve taken some time to reflect and read up more, especially on the German CFC rules and how they apply to foundations and nominee setups.
I now fully understand that any structure managed from Germany, even indirectly, can trigger CFC and other reporting obligations. That’s why I’ve adjusted my approach:

-I intend to pay taxes in Germany while I’m still here
- I’m gradually preparing for relocation (within 1–2 years)
- I’d like to build a clean and professional setup that I won’t need to dismantle once I leave

So here’s my updated question:
What kind of structure would you recommend for someone still residing in Germany, paying taxes properly, but aiming to “bridge” into long-term offshore independence with a view to relocating soon?

Do I really need something like a Foundation and Nominees now, or would a simple IBC (fully declared) be sufficient for this transition phase?

Also, correct me if I’m wrong, but only setting up a local Gewerbe (sole proprietorship), without a proper structure (IBC, etc) in Germany might limit future flexibility due to things like “exit tax,” local bank account ties, and the need to rebuild infrastructure abroad.

I’d greatly appreciate thoughts, especially from those who’ve gone through a similar transition.
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You mentioned relocation to Cyprus, why not immediately the Cyprus Ltd? Now that you are aware of the tax situation, that cannot be an issue anymore.

By being in CY it also allows you to build up a local CY presence while you are still in DE.
 
#25
Protect Your Wealth said:
One of the best temporary relocation for OP could be Albania
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what makes you say best? the tax rates themselves or do you recommend the albanian life?

Protect Your Wealth said:
You pay 0% taxes on the first 140k euros/year you make and then 15% on what is above that
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is that so? the PWC summary seems to indicate its 15% below and 23% above, but 0% while you are under the 14m ALL
it also seems that's not the same thing as CIT which is just fixed 15% as i understand, i don't know anything about Albania and am not sure what exactly "commercial individuals and the self-employed" means exactly, and if OP would fit the criteria
it looks to me like OP would be paying 15% CIT + 8% dividend tax + living in Albania, this doesn't sound good at all.
 
#26
drysponge said:
what makes you say best? the tax rates themselves or do you recommend the albanian life?


is that so? the PWC summary seems to indicate its 15% below and 23% above, but 0% while you are under the 14m ALL
it also seems that's not the same thing as CIT which is just fixed 15% as i understand, i don't know anything about Albania and am not sure what exactly "commercial individuals and the self-employed" means exactly, and if OP would fit the criteria
it looks to me like OP would be paying 15% CIT + 8% dividend tax + living in Albania, this doesn't sound good at all.
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* Note that for commercial individuals and the self-employed (as well as entities) with an annual gross income up to ALL 14 million, the PIT rate will be 0%, applicable until 31 December 2029.
 
#32
drysponge said:
what makes you say best? the tax rates themselves or do you recommend the albanian life?


is that so? the PWC summary seems to indicate its 15% below and 23% above, but 0% while you are under the 14m ALL
it also seems that's not the same thing as CIT which is just fixed 15% as i understand, i don't know anything about Albania and am not sure what exactly "commercial individuals and the self-employed" means exactly, and if OP would fit the criteria
it looks to me like OP would be paying 15% CIT + 8% dividend tax + living in Albania, this doesn't sound good at all.
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Tax rates and cost of life mainly, also if you've been in zones like Valona, you experience a lifestyle quite mediterranean.

Of course we are not talking about employment income, that is taxed differently. I am referring to Law n29 of march 2023. 14M ALL are roughly 140K EUR as of today.
 
#33
anceps said:
Hey everyone,


I'm running a small but growing digital agency based in Germany. The core of my business is:


  • Connecting brands with influencers (commission-based, like a talent manager)
  • Some video editing and content consulting as additional services

I'm now looking into offshore structuring, mainly for privacy, long-term tax efficiency, and more flexible banking as my clients are global. I've been speaking with Offshore Companies International (OCI) and got a very comprehensive email from them laying out a proposed structure:


Seychelles Private Foundation to hold
a Panama / Seychelles / HK IBC, which would carry out the business
Myself acting as a "consultant" to the company (instead of owner/director)
Nominees to reduce CFC exposure


The guy I spoke to seems very experienced and gave a detailed explanation about Germany’s CFC laws and why a private Foundation + IBC combo is the "cleanest" way to go. The pitch is that the Foundation owns the company, so I’m not "controlling" a CFC directly, which might help with deferral or privacy.


My questions to the group:


  1. Does this structure (Foundation + IBC with nominee director) actually hold up in practice, or is it just offshore theory that doesn’t fly under scrutiny?
  2. Has anyone here used OCI and can vouch for them (or warn against them)?
  3. They mentioned Hong Kong for banking/merchant accounts , is that still viable in 2025?

Not looking to hide income, just exploring compliant ways to structure things efficiently and privately, especially with future relocation in mind.


Appreciate any honest thoughts or provider recommendations. Open to DMs too if you have specific experiences you can’t post publicly.
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You make it very complicated for your self for a small digital company in Germany!

Why don't you wait until you have a big company with millions in turnover and then structure things. You could preferable setup a Holding company abroad but which get taxed in Germany or so, but it would make a transition later easier.
 
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